California Transparency Act Disclosure

PolyOne is an intermediate supplier of specialty polymers and related raw materials designed to meet the specifications of its manufacturing customers. PolyOne does not manufacture or sell totally finished articles to be sold as consumer goods. In sourcing its own raw materials and in distributing products manufactured by others, PolyOne is required to meet the specifications prescribed by its customers.

In its Supplier Code of Conduct, PolyOne prescribes that its suppliers should not use slavery or human trafficking in connection with any product supplied to PolyOne. PolyOne currently does not engage in verification of its supply chains to evaluate and address risks of human trafficking and slavery, nor does it currently conduct audits of its suppliers’ compliance with company standards for trafficking and slavery in supply chains. PolyOne currently does not require direct suppliers to certify that the materials incorporated into their product comply with the laws regarding slavery and human trafficking.

PolyOne includes in its Code of Conduct internal accountability standards related to slavery and human trafficking to which all employees, agents and consultants are required to adhere. In its training programs for employees and managers with direct responsibility for supply chain management, PolyOne is planning to include the need to mitigate the risks of slavery and human trafficking within supply chains.